Disclaimer - Appendix F
The sample Contingency Plan in Appendix F is intended to provide examples of contingency planning as a reference when a facility determines that the required secondary containment is impracticable, pursuant to 40 CFR §112.7(d). The sample Contingency Plan presents a variety of scenarios for purposes of illustration only. It is not a template to be adopted by a facility; doing so does not mean that the facility will be in compliance with the SPCC rule requirements for a contingency plan. Nor is the sample plan a template that must be followed in order for the facility to be considered in compliance with the contingency plan requirement.
Version 1.0, 11/28/2005
Clearwater Oil Company, Ltd.
Big Bear Lease No. 2 Production Facility Oil Spill Contingency Plan
Clearwater Oil Company
Big Bear Lease No. 2 Production Facility
Oil Spill Contingency Plan
Part I
Introduction
-1-
Version 1.0, 11/28/2005
Clearwater Oil Company, Ltd.
Big Bear Lease No. 2 Production Facility Oil Spill Contingency Plan
1.1 Purpose and Scope
This Oil Spill Contingency Plan is prepared in accordance with 40 CFR 112.7(d) to address areas of the facility where secondary containment is impracticable, as documented in the facility Spill Prevention, Control, and Countermeasure (SPCC) Plan.
The purpose of this Oil Spill Contingency Plan (“Contingency Plan”) is to define procedures and tactics for responding to discharges of oil into navigable waters or adjoining shorelines of the United States, originating more specifically from flowlines at Clearwater Oil Company (“Clearwater”) Big Bear Lease No. 2 Production Facility. The Contingency Plan is implemented whenever a discharge of oil has reached, or threatens, navigable waters or adjoining shorelines.
The objective of procedures described in this Contingency Plan is to protect the public, Clearwater personnel, and other responders during oil discharges. In addition, the Plan is intended to minimize damage to the environment, natural resources, and facility installations from a discharge of oil. This Oil Spill Contingency Plan complements the prevention and control measures presented in the facility’s SPCC Plan by addressing areas of the facility that have inadequate secondary containment and impacts that may result from a discharge from these areas. The facility implements a detailed and stringent flowline maintenance program to prevent leaks from the primary system (in this case, piping). Areas lacking adequate containment at the Big Bear Lease No. 2 Production Facility include the flowlines that run between the extraction wells and the tank battery area and between the tank battery area and the saltwater disposal area.
This Oil Spill Contingency Plan follows the content and organization of 40 CFR part 109 and describes the distribution of responsibilities and basic procedures for responding to an oil discharge and performing cleanup operations.
1.2Resources at Risk
Clearwater’s Big Bear Lease No. 2 Production Facility is located approximately 6 miles North of Madison, LA, within the Mines River watershed (see Figure C-1 in Appendix C). The waterways closest to the facility are Big Bear Creek, which flows approximately ½ mile to the east of the facility, and the Mines River, which flows 6 miles to the south in a west-to-east direction and receives water from Big Bear Creek. The facility diagram included in Appendix C (Figure C-2) indicates the location of the oil extraction, production, and storage areas. Ground cover at the facility consists of compacted soil, gravel, and low lying vegetation. The natural topography of the land is graded in an east-southeast direction, and all surface drainage from the facility therefore flows towards Big Bear Creek. The slope is relatively mild: approximately 4 feet vertical per mile (5,280 feet) horizontal.
Three flowlines (which contain oil) at the facility lack adequate secondary containment (see Figure C-2):
•Flowline A. The flowline from Well A to the tank battery (FLA) is approximately 2,100 feet long. It runs aboveground in a north-south direction to the tank battery area.
•Flowline B. The flowline between Well B and the tank battery (FLB) is approximately 3,400 feet long. It travels in a southwest direction to the tank battery area. This flowline runs the closest to navigable waters. At the closest point, the flowline is located ½ mile from Big Bear Creek.
•Flowline SWD. The flowline between the tank battery and the saltwater disposal well is approximately 2,000 feet long. It runs in an east-west direction.
All three flowlines are aboveground, with the exception of a short portion of Flowline B that is buried under the dirt/gravel access road. A drainage ditch runs along the access road to the east of the tank battery and along Route 417. The ditch flows into Big Bear Creek. Given the direction of surface drainage, a discharge from any of the three flowlines could reach Big Bear Creek, either directly or via the drainage ditch, and from there, flow southward to the Mines River.
Neither Big Bear Creek nor the Mines River is used as a public drinking water supply, although animals grazing on the nearby land are often seen drinking from Big Bear Creek and the Howard Fleming Farm has an agricultural irrigation intake on Big Bear Creek (see the Notification Form later in this Plan for contact information). The two waterways, however, provide habitat for a number of aquatic species and mammals and are used by local residents for recreational purposes. The Mines River runs through the center of Madison. Recreational and scenic areas are located on both banks of the river. A public park is located approximately 1 mile east from the town center and 8 miles from the facility. Recreational uses on the Mines River include picnic areas, walking trails, canoeing, and nature watching.
There are no residences within the immediate vicinity of the facility. The closest residence is located 1 mile to the north of the site, upstream on Big Bear Creek. The closest residence downstream from the site is located 3 miles away. Both residences have private drinking water wells. Clearwater will coordinate with the Madison fire and/or police departments and with its residential neighbors to provide the appropriate warnings in the event of a discharge that could affect public health and safety.
1.3Risk Assessment
The facility is comprised of approximately 7,500 feet of 2-inch diameter flowlines. With the exception of a short road crossing, the flowlines are located aboveground. The flowlines do not have secondary containment, since such containment is impracticable at this facility (see discussion on impracticability of secondary containment in the facility’s SPCC Plan).
The total daily production rate at the facility varies, but can reach as much as 1,260 gallons of crude oil and 5,880 gallons of produced water. The two wells have approximately equal production rates (each 3,570 gallons per day). Flowline B, the longest of the three flowlines and the one closest to navigable waters, contains up to 555 gallons of oil/water when charged. The facility is visited daily. For planning purposes, the worst-case discharge is therefore the volume of oil within the flowline plus 24 hours of production, or 4,125 gallons.
A discharge of this quantity of oil could potentially reach Big Bear Creek. The velocity of oil over land is estimated, based on past experience and a simple calculation of flow over short grass pastureland, at approximately 0.2 feet/second.[1] Considering the distance between Flowline B and Big Bear Creek (½ mile) and the 2-foot elevation gradient, the oil, if unimpeded, could reach Big Bear Creek in as little as 4 hours. The water current in Big Bear Creek averages approximately 0.3 feet/second during high stages. Over a 24-hour period, the oil could travel approximately 5 miles downstream from the release point. The Mines River, which is located only 6 miles downstream to the south of the tank battery area, could therefore possibly be affected by a discharge.
1.4Response Strategy
Clearwater personnel and contractors are equipped and trained to respond to certain “minor discharges” confined within the facility. Minor discharges can generally be described as those where the quantity of product discharged is small, the discharged material can be easily stopped and controlled, the discharge is localized, and the product is not likely to seep into groundwater or reach surface water or adjoining shorelines. Procedures for responding to these minor discharges are covered in the SPCC Plan.
This Contingency Plan addresses all discharge incidents, including those that affect navigable waters or during which the oil cannot be safely controlled by facility personnel and confined within the boundaries of the facility. Response to such incidents may necessitate the assistance of outside contractors or other responders to prevent imminent impact to navigable waters.
Part II
Spill Discovery and Response
2.1Distribution of Responsibilities
Clearwater has the primary responsibility for providing the initial response to oil discharge incidents originating from its facility. To accomplish this, Clearwater has designated the Field Operations Manager, Bill Laurier, as the qualified oil discharge Response Coordinator (RC) in the event of an oil discharge.
The RC plays a central coordinating role in any emergency situation, as illustrated in the emergency organization chart in Figure 2-1.
The RC has the authority to commit the necessary services and equipment to respond to the discharge and to request assistance from Madison fire and/or police departments, contractors, or other responders, as appropriate.
The RC will direct notifications and initial response actions in accordance with training and capabilities. In the event of a fire or emergency situation that threatens the health and safety of those present at the site, the RC will direct evacuations and contact the fire and police departments.
In the event of an emergency involving outside response agencies, the RC’s primary responsibility is to provide information regarding the characteristics of the materials and equipment involved and to provide access to Clearwater resources as requested. The RC shall also take necessary measures to control the flow of people, emergency equipment, and supplies and obtain the support of the Madison Police Department as needed to maintain control of the site. These controls may be necessary to minimize injuries and confusion.
Finally, the RC serves as the coordinator for radio communications by acquiring all essential information and ensuring clear communication of information to emergency response personnel. The RC has access to reference material at the field office either as printed material or on computer files that can further assist the response activities.
Whenever circumstances permit, the RC transmits assessments and recommendations to Clearwater Senior Management for direction. Senior Management is contacted in the following order: (1) Regional Director of Operations; (2) Vice-President of Operations.
In the event that the Field Operations Manager is not available, the responsibility and authority for initiating a response to a discharge rests with the most senior Clearwater employee on site at the time the discharge is discovered (Crew Lead) or with the contractor Field Supervisor (or next person in command) if contractor personnel are the only personnel on site.
Figure 2-1. Distribution of response authority and communication.
2.2Response Activities
In the event of a discharge, the first priority is to stop the product flow and to shut off all ignition sources, followed by the containment, control, and mitigation of the discharge. This Contingency Plan breaks actions to be performed to respond to an oil discharge into different phases, described in greater detail in the checklists below.
2.2.1Discharge Discovery and Source Control
Minor Discharge. A minor discharge (i.e., small volume leak from flowlines or other equipment) will be discovered by Clearwater facility personnel or by contractor personnel during scheduled daily or monthly visits to the facility. Aboveground flowlines are visually inspected formally once a month during the normal inspection rounds.
Major Discharge. A more severe and sudden discharge will trigger the automatic shut down of the pumping units and will affect oil production. The impact will be detected during the daily visit to the production area by Clearwater or contractor field personnel. The maximum amount of time until a major discharge is detected can be up to 24 hours.
Notifications to the National Response Center, Louisiana authorities, and St. Anthony’s Parish Emergency Committee must occur immediately upon discovery of reportable discharges.
Completed / ActionsImmediately report the discharge to the RC, providing the following information:
$Exact location;
$Material involved;
$Quantity involved;
$Topographic and environmental conditions;
$Circumstances that may hinder response; and
$Injuries, if any.
Turn off all sources of ignition.
Turn off lift pumps that charge or provide flow to the flowline.
Locate the flowline break.
If safe to do so, isolate the affected section of piping by closing off the closest valves upstream and downstream from the break.
2.2.2Assessment and Notifications
Completed / ActionsInvestigate the discharge to assess the actual or potential threat to human health or the environment:
$Location of the discharge relative to receiving waterbodies;
$Quantity of spilled material;
$Ambient conditions (temperature, rain);
$Other contributing factors such as fire or explosion hazards; and
$Sensitive receptors downstream.
Request outside assistance from local emergency responders, as needed.
Evaluate the need to evacuate facility and evacuate employees, as needed.
Notify the fire/police departments and St. Anthony’s Parish Emergency Committee to assess whether community evacuation is needed.
Notify immediately:
$911
$National Response Center
$Response contractor(s)
$St. Anthony’s Parish Emergency Planning Committee
$State authorities
Communicate with neighboring property owners regarding the discharge and actions taken to mitigate the damage.
If the oil reaches (or threatens to reach) the Mines River, notify the local fire/police departments to limit access to the River by local residents until the oil has been contained and recovered.
Additionally, notify downstream water users of the spill and of actions that will be taken to protect these downstream receptors.
2.2.3Control and Recovery
The RC directs the initial control of the oil flow by Clearwater, Avonlea Oil Services, and other contractor personnel. The actions taken will depend on whether the oil has reached water or is still on land. All effort will be made to prevent oil from reaching water.
If the oil has not yet reached water:
Completed / ActionsDeploy sand bags and absorbent socks downgradient from the oil, or erect temporary barriers such as trenches or mounds to prevent the oil from flowing towards Big Bear Creek.
Implement land based response actions (countermeasure) such as digging temporary containment pits, ponds, or curbs to prevent the flow of oil into the river.
Deploy absorbent sock and sorbent material along the shoreline to prevent oil from entering waters.
If the oil has reached water:
Completed / ActionsContact cleanup contractor(s).
Deploy floating booms immediately downstream from the release point. Big Bear Creek is narrow and shallow. Floating boom deployment does not require the use of a boat.
Control oil flow on the ground by placing absorbent socks and other sorbent material or physical barriers (e.g., “kitty litter,” sandbags, earthen berm, trenches) across the oil flow path.
Deploy additional floating booms across the whole width of the Creek at the next access point downstream from the release point. Access points and staging areas along the shoreline are identified on Figure C-1 of this Contingency Plan.
Deploy protective booming measures for downstream receptors that may be impacted by the spill.
2.2.4Disposal of Recovered Product and Contaminated Response Material
The RC ensures that all contaminated materials classified as hazardous waste are disposed of in accordance with all applicable solid and hazardous waste regulations.
Completed / ActionsPlace any recovered product that can be recycled into the gun barrel tank to be separated and recycled.
Dispose of recovered product not suitable for on-site recycling with the rest of the waste collected during the response efforts.
Collect all debris in properly labeled waste containers (impervious bags, drums, or buckets).
Dispose of contaminated material in accordance with all applicable solid and hazardous waste regulations using a licensed waste hauler and disposal facility, after appropriately characterizing the material for collection and disposal.
Dispose of all contaminated response material within 2 weeks of the discharge.
2.2.5Termination
The RC ensures that cleanup has been completed and that the contaminated area has been treated or mitigated according to the applicable regulations and state/federal cleanup action levels. The RC collaborates with the local, state and federal authorities regarding the assessment of damages.
Completed / ActionsEnsure that all repairs to the defective equipment or flowline section have been completed.
Review circumstances that led to the discharge and take all necessary precautions to prevent a recurrence.
Evaluate the effectiveness of the response activities and make adjustments as necessary to response procedures and personnel training.
Carry out personnel and contractor debriefings as necessary to emphasize prevention measures or to communicate changes in operations or response procedures.
Submit any required follow-up reports to the authorities.
40 CFR 112.4(a)In the case where the discharge (as defined in 40 CFR 112.1(b)) was greater than 1,000 gallons or was the second discharge (as defined in 40 CFR 112.1(b)) of 42 gallons or more within any 12-month period, the RC is responsible for submitting the required information within 60 days to the EPA Regional Administrator following the procedures outlined in Appendix B.
Within 30 days of the discharge, the RC will convene an incident critique including all appropriate persons that responded to the spill. The goal of the incident critique is to discuss lessons learned, the efficacy of the Contingency Plan and its implementation, and coordination of the plan/RC and other state and local plans.
Within 60 days of the critique, the Contingency Plan will be updated (as needed) to incorporate the results, findings, and suggestions developed during the critique.